UST_Monitoring_System_for_FDO_report_0001.docx

Subject: 2022 UST Operations Inspection Report, ADEC Facility #3052 The Alaska Department of Environmental Conservation received the 2022 UST Operations Inspection Report on the following underground storage tank (UST) system, which did not pass operational and maintenance compliance in accordance with Title 18 Alaska Administrative Code (AAC) 78, Underground Storage Tanks.

Facility Name: BLM Northern District Office ADEC Facility #3052 Address: 222 University Avenue City: Fairbanks ADEC Tank Owner Tank Contents Volume Compliance Tag 1 1 Diesel 10,000 gal 1180 Corrosion Protection Survey. Metal components in contact with soil, that routinely contain fuel, must be inspected and tested each three years. Your UST inspector, Larry Larweth, conducted the survey on August 9, 2022, which met coverage criteria of at least -850 millivolts (18 AAC 78.045(c)).

Walkthrough Inspections. New UST rules were put into effect October 2015, with compliance to begin by October 2018. Title 18 AAC 78 was updated to include the changes to leak detection, spill/overfill prevention integrity, records retention, and walkthrough inspections (18 AAC 78.058).

Periodic walkthrough inspections have not been logged.

Spill and overfill prevention must be integrity tested each three years (18 AAC 78.025(g)(4)). UST inspector Larry Larweth integrity tested the spill bucket for liquid tightness August 9, 2022 (78.057(a)(1)).

He noted the outer wall of the spill bucket is cracked and broken but did not affect the integrity test.

Overfill prevention (drop tube and automatic shutoff valve) were inspected for regulatory and industry standards on August 9, 2022. The drop tube extends to within six inches of the tank bottom to prevent vibration and spark hazard (78.025(h)(4)(E)). The automatic shutoff valve is set four inches too high, which does not activate when fuel transfer reaches 95 percent of tank volume (78.025(g)(1)(B). It is a non-testable type (EBW brand) which must be upgraded.

Release detection components, such as the automatic tank gauge (ATG), tank inventory probes, and interstitial liquid sensors, must be inspected each 12 months (18 AAC 78.060(a)(5)). Larry noted the printer doesn’t function and the console is no longer supported by the manufacturer.

The piping is configured as safe suction, which doesn’t require tightness testing on the sump or lines but interstitial monitoring is operating (78.060(f)(1)(B), 78.070(d), (78.065(h)).

ADEC Facility #3052-BLM Northern District Office 2 December 5, 2022 2022 UST Operations Inspection Report Letter, Notice of Non-Compliance #6814 The primary tank leak detection is interstitial monitoring, which was not checked at least once each 30 days, nor were 12 months of records retained (78.065(h), 78.060(e)(1)). The secondary leak detection method on the tank is via ATG, which should perform a monthly 0.2 gph leak rate test, but the monitor photograph included with the inspection report shows an inconsistent test schedule with gaps of several months. If it now programmed to perform a monthly 0.2 gph leak rate test, then photograph the monitor at least once each 30 days and retain a rolling 12 months of records.

Leak Detection Probation (LDP): Your UST will be on 30-day fuel authorization program for at least one year, requiring you to submit the ATG or liquid status reports with walkthrough inspection logs.

UST Class A and B Operator(s) have not been appointed, trained, certified, and designated, in writing, to carry out UST daily responsibilities as required under 18 AAC 78.355-78.385 ; operators must be assigned, trained, certified, and designated, in writing within 30 days (18 AAC 78.360, 78.370(b)).

You are required to:

• Upgrade the automatic shutoff valve no later than January 30, 2023; verify it activates to stop fuel transfer when it reaches 95 percent of volume, (18 AAC 78.030(f), (78.030(c), 78.055(a))

• Use a licensed UST installer, who must submit the signed Addendum, including verification results, within 30 days of the work (78.035(e), 78.055(a)(7), 78.455(a)(9), 78.056(a)(2)).

• Appoint, certify, train and designate, in writing, at least one UST Class A and B Operator,